INTRODUCTION Welcome to SwanChat We value your privacy. This Privacy Policy informs you of your choices and our practices regarding any Information you provide to us. The use of SwanChat (through the SwanChat mobile app, any third party platforms through which SwanChat is provided) may involve the collection and use of your Information. It is important for you to understand how this happens and how you may control it, so please read this Privacy Policy carefully. By using SwanChat, you agree that we may collect, use, store and share your Information in accordance with this Privacy Policy, as revised from time to time. If you change your mind in the future, you may withdraw this consent at any time in accordance with this Privacy Policy.

If you do not agree with this Privacy Policy, you must not use SwanChat. If you wish to contact us regarding this Privacy Policy or any privacy-related matters, please contact: SCOPE AND APPLICATION OF THIS PRIVACY POLICY This Privacy Policy applies to SwanChat, including any services related with SwanChat that incorporates this Privacy Policy by reference (for example, the SwanChat Official Account Admin Platform). Those SwanChat services may have further privacy-related terms that you must agree to if you use those services. This Privacy Policy is incorporated into and forms part of the SwanChat Terms of Service that you have agreed to in order to use SwanChat. Any terms used in this Privacy Policy will have the same meaning as the equivalent defined terms in the SwanChat Terms of Service, unless otherwise defined in this Privacy Policy or the context requires otherwise.

Please note that this Privacy Policy does not apply to Information collected:

(a) through any services other than SwanChat;
(b) through any third party services (including any third party websites) that you may access through SwanChat; or (c) by other companies and organisations who advertise their services on SwanChat. If you are using SwanChat on behalf of a company, partnership, association, government or other organisation (your "Organisation"), you agree to notify your Organisation's relevant individual owners, shareholders, directors, officers, managers, employees and other relevant individuals whose Personal Information we collect or you provide to us from time to time ("Connected Persons") of the collection of their Personal Information, and you agree to obtain your Connected Persons' consent to the processing of their Personal Information in accordance with this Privacy Policy as required by applicable laws and regulations. Where throughout this Privacy Policy we refer to “you” or “your”, this applies to the Personal Information of Connected Persons.

CHANGES TO THIS PRIVACY POLICY We may from time to time revise or add specific instructions, policies and terms to this Privacy Policy. These instructions, policies and terms form part of this Privacy Policy. Whenever we make any changes to this Privacy Policy that are important for you to know about, we will notify you via SwanChat or other means before the change becomes effective.

THE INFORMATION WE COLLECT
In providing SwanChat, we collect, store and use the following Information relating to you: “Information” is Personal Information and Non-Personal Information; "Personal Information" is any information or combination of information that relates to you or a Connected Person, and can be used to identify you or a Connected Person. We set out examples of Personal Information (and how we collect such Personal Information) in the "How we collect Information via SwanChat " section below. “Location Data” is information that we collect regarding your location (when you use a location-enabled service), including: the location of your device when you use SwanChat, such as from the GPS, WiFi, compass, accelerometer or other sensors in your mobile device; the IP address of the device or internet service you use to access SwanChat; and other information made available by you or others that gives an indication as to where you are or have been located, such as account information that indicates where you are located, and Shared Information that you or others post which indicates your location (for example, any geotag information that is embedded in any photos you make available on SwanChat or that is made available to us when you use the SwanChat "Shake" or "People Nearby" functions). "Log Data" is technical information that is automatically collected by us when you use SwanChat, whether through the use of cookies, web beacons, log files, scripts and ETags (as explained in more detail in the “Tracking Technologies” section below) or otherwise, including: technical information, such as your mobile carrier-related information, configuration information made available by your web browser or other programs you use to access SwanChat, your IP address and your device’s version and identification number; information about what you have searched for and looked at while using SwanChat, such as web search terms used, social media profiles visited and details of other information and content accessed or requested by you in using SwanChat; information about communications you have made using SwanChat, such as the people you’ve communicated with and the time, data and duration of your communications; and metadata, which means information related to items you have made available through SwanChat, such as the date, time or location that a shared photograph or video was taken or posted. “Non-Personal Information” is any information that relates to you but from which it is not reasonably practicable to directly or indirectly identify you, including Personal Information in aggregated, anonymised or pseudonymised form. “Shared Information” is information about you or relating to you that is voluntarily shared on SwanChat. Shared Information may include postings that you make on SwanChat (including your public profile, the lists you create, and photos, videos and voice recordings as accessed with your prior consent through your device’s camera and/or microphone sensor), any postings from others that you re-post and Location Data and Log Data associated with such postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using SwanChat share about you.

HOW WE COLLECT INFORMATION VIA SWAN CHAT
We collect Information from you when you use SwanChat – for example, when you: register to use SwanChat; log into SwanChat with third party platform accounts; use SwanChat; and communicate with us. The following sets out how we collect such Information from you as you use SwanChat. The remainder of this Privacy Policy sets out further information regarding some of these categories. Registration and Account Information. You must register for a SwanChat account in order to use SwanChat. To register, you may need to provide certain Personal Information, such as your name, mobile phone number and password. Account Verification. If you choose to apply for account verification (in order to unlock additional payment and fund settlement features in SwanChat) you may need to provide additional Personal Information, including gender, nationality, date of birth, residential address, copy of residential address proof, copy of personal identification document (for example passport, identification card, home return permit, etc.), personal identification document number, occupation and source of funds Connected Persons. If you are an Organization you may provide information related to Connected Persons to allow us to administer your SwanChat account and comply with laws and regulations applicable to us and our affiliated companies. Social Connect. When you choose to connect your third party social media account to your SwanChat account, we may collect certain Information from your account with that social media platform – for example, to facilitate your login to SwanChat with that account. Using SwanChat. We collect Information from and about you through your use of SwanChat. For example, we may collect Personal Information from you within SwanChat via the following: information you make available to us when you open a SwanChat account, as set out above; any information included in your publicly visible SwanChat profile, which may include your profile ID, name and photo; information you make available to us via your use of SwanChat – for example, via: posting SwanChat Moments and responding to other users' SwanChat Moments; your sharing of your contact list with SwanChat in the "Recommended Friends" function in order to connect with other SwanChat users; participating in surveys, polls, contests, giveaways and other promotional activities within SwanChat; making purchases within SwanChat, including your credit card or bank details and information about the purchases that you make; your sharing of your biometric information via SwanChat – e.g. by using your voice to authenticate your identity and log into SwanChat via Voiceprint; information made available by another user about you via their use of SwanChat – for example, any Shared Information that others using SwanChat make available about you via SwanChat Moments and communications they make to you and others using SwanChat; information we collect in the course of you using SwanChat – such as certain Location Data and Log Data; and information you provide through your communications with our customer support team. Purchases via SwanChat. When you make purchases through SwanChat, you may need to provide certain Personal Information to complete the purchase, such as your credit card information or bank account information. Where the payment is processed by a third party payment service provider, we do not collect or store such Personal Information, though we may receive summary information about transactions. Where we or our affiliate companies process your payments as a payment service provider, or where we fulfil any purchases you have made on SwanChat, we may collect, use and store your Personal Information in order to fulfil such purchases. "Such as" Working with our third party partners. We may work with third parties to gather additional demographic information about our users on an aggregate and anonymised basis. Location Data, Log Data and your device. SwanChat automatically collects Log Data from your device to enable and assist SwanChat 's functionalities. In addition, you may also permit SwanChat to access other content and data on your device – for example, your contact list and photo storage. Cookies, Automatic Data Collection, and Related Technologies. We further explain such collection in the "Tracking Technologies" section below.

HOW WE USE YOUR INFORMATION
Use of your Information within SwanChat We may use your Information for any of the following purposes: to provide SwanChat (and the features and services within SwanChat) to you – for example, to allow you to place VOIP calls within SwanChat, to fulfil any purchases you may make within SwanChat, and to display content based on your location; for communication, verification, security, fraud-detection, archival, backup, informational and operational purposes in connection with the provision of SwanChat – including account management, customer service, system maintenance, fulfilment of purchases, notifying contest winners, and other SwanChat -related purposes; to provide you with advertising and direct marketing that is more relevant to you (as further discussed under the “Direct Marketing” section below); to better understand how you access and use SwanChat, in order for us to improve SwanChat and respond to customer desires and preferences, including for us to provide language and location customisation, personalised help and instructions, or other responses to your and other customers’ usage of SwanChat; to help us develop our new services and improve our existing services; to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with SwanChat t when your account is subscribed to an official account; and to allow you to participate in voluntary surveys about our products and services. If you choose to participate in a survey, we may request certain Personal Information from you. We may use a third party service provider to conduct these surveys; we will prohibit them from using your Personal Information for any purpose other than to complete the survey. In addition, we may need to retain, disclose and use your Information for the following purposes (collectively, the "Retained Information Purposes"): to comply with applicable laws and regulations; to comply with a court order, subpoena or other legal process, whether binding on us or any of our affiliates in any jurisdiction; in response to a request by a government authority, law enforcement agency or similar body made to us or any of our affiliate companies (whether situated in your jurisdiction or elsewhere); where we believe it is reasonably necessary to comply with applicable laws or regulations; to enforce the SwanChat Terms of Service or this Privacy Policy; and to protect any rights, property or safety of ours, our affiliate companies or other users of SwanChat. We may also anonymise or aggregate any Personal Information collected through SwanChat and use such anonymised and aggregate data for any purpose. Use of Personal Information on our other services In order to provide our users across SwanChat and our other services with a better experience, to improve SwanChat and our other services, or otherwise where you have consented, Personal Information collected through SwanChat may, subject to user privacy controls (where available), be used by our other services (whether in an aggregated or individualised manner) in accordance with the relevant privacy policy for those other services. For example, Personal Information collected during your use of SwanChat may be used to suggest particular content that can be made available to you on, or be used to present more relevant advertising to you in Personal Information within Your Content If any of your Personal Information comprises Your Content (as defined in the SwanChat  Terms of Service), we and our affiliate companies may (subject to this Privacy Policy) use such Personal Information in accordance with the “Your Content” section of the SwanChat Terms of Service.

DIRECT MARKETING
We may use your Information for the purpose of sending you direct marketing (whether by messaging within our services, by email or by other means) that offer or advertise our products and services and/or the products and services of selected third parties. Such products and services (of ours or third parties) include the following: our products and services and the products and services of our affiliate and subsidiary companies and joint venture partners, including messaging services, online media services, interactive entertainment services, social networking services, payment services, internet search services, location and mapping services, application software and services, data management software and services, on-line advertising services and other social media, entertainment, e-commerce, information and communications software and services (“Internet Services”); and third party providers of Internet Services and products and services relating to dining, food and beverages, sports, music, film, television, live performances and other arts and entertainment, books, magazines and other publications, clothing and accessories, jewellery, cosmetics, personal health and hygiene, electronics, collectibles, housewares, appliances, home decoration and furnishings, pets, automobiles, hotels, transport and travel, banking, insurance and financial services, loyalty and reward programs and other products and services that we think may be relevant to you. We will honour your request for us to not use your Personal Information for the direct marketing purposes noted above. If you wish to make such a request, please contact our Privacy Officer at any time and free of charge. In addition, you may be able to opt-out of certain direct marketing by following the relevant instructions set out on our marketing communications. We will not share your Personal Information with advertisers unless we have your permission to do so. We do, however, share Non-Personal Information with advertisers for the purposes of trying to offer you advertising that is more relevant to you. When you opt out of direct marketing pursuant to the above, you may continue to see online advertising (that is not direct marketing) within SwanChat and/or our advertisements on other websites or applications.

SHARING OF YOUR PERSONAL INFORMATION WITH THIRD PARTIES
Other than as permitted under this Privacy Policy or as otherwise consented to by you, we will not transfer your Personal Information to any other third parties for their processing for any purposes. Sharing for the provision of SwanChat We may share your Personal Information within our group of companies and with joint venture partners and third party service providers, contractors and agents (such as communication service providers who send emails or push notifications on our behalf, and mapping services providers who assist us and you with location data), in each case, for the following purposes: providing SwanChat to you; assisting us in carrying out the purposes set out under the “How We Use Your Information” section above; carrying out our obligations and enforcing our rights under the SwanChat Terms of Service or this Privacy Policy; and/or helping us understand and improve SwanChat. Sharing for marketing purposes We may allow third party marketing partners (such as SwanChat Official Accounts partners, analytics providers and advertising partners) to collect your Personal Information over time and across different websites or online services when you use SwanChat. If you wish to opt-out of such collection of your Personal Information by our third party marketing partners while you are using SwanChat, please contact us  We may also provide your Personal Information to third party marketing partners where you have asked us or consented to us doing so or where it is required in order for us to provide SwanChat to you. Other terms relating to the sharing of your Personal Information Where we or our affiliate companies share your Personal Information with any third parties, we will use reasonable efforts to ensure that such third parties only use your Personal Information: in compliance with this Privacy Policy; and subject to any other instructions and restrictions as required by us, including any appropriate confidentiality and security measures that we implement. As we continue to develop our business, we or our affiliate companies may be acquired by a third party or re-organise our group structure. In these circumstances, your Information may be transferred within our group and/or to a third party who will continue to operate SwanChat or similar services under either this Privacy Policy or a different privacy policy that will be provided to you. The party to which your Personal Information is transferred may be located, and use your Information, outside of your home country. We may also be required to retain, preserve or disclose your Personal Information under the circumstances set out in the "Period of use of your Personal Information" section below.

COMMUNICATIONS FROM US
Newsletters and other types of communications When you use SwanChat, we may use your Information to send you emails, messages, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level (if available) or contacting our Privacy Officer. Service-related announcements We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend SwanChat for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.

A WORD ABOUT SENSITIVE PERSONAL INFORMATION

In some jurisdictions, certain types of Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterised as “sensitive” and is subject to stricter regulation than other types of Personal Information. Please note that content and information that you input to SwanChat, such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others. Before communicating any Personal Information of a sensitive nature within SwanChat, please consider whether it is appropriate to do so. You consent to all processing of sensitive Personal Information for the purposes and in the manner described in this Privacy Policy. Please note that we do not use your sensitive Personal Information for the purpose of serving advertising to you.

THIRD PARTY SERVICES AND YOUR INFORMATION
SwanChat may link you to social media or other features or services (including websites, plug-ins and widgets) provided by, or allow you to share certain Information with, a third party. For example: you may share content on, or login to, SwanChat using services provided by third parties. These third party services will authenticate your identity and provide you with the option to share certain Personal Information with us. They may also give you the option to post information from your third party service account to SwanChat as Shared Information (or vice versa), and to share other information with such third parties. you may link your SwanChat contact list to your contact lists on your device and/or in your account on third party services, in order to search for and connect with contacts on those contact lists who also have a SwanChat account. In consenting to such linking, we will use your username and password for the relevant third party service only for the purpose of such contact list linking (and will delete such information immediately after such purpose is completed); you may login to SwanChat using other sign-in services such as an Open ID provider. These sign-in services will authenticate your identity and provide you the option to share certain Personal Information with us for account registration and login purposes, such as your name and email address; and we may (whether in advertisements or otherwise within SwanChat) provide you with links or features that allow you to access third party services or websites (or access within SwanChat content that is hosted on those third party services or websites). For example, you may be able to access videos hosted by a third party within SwanChat. These third party social media or other services may be hosted by the relevant third party or us. Please note that third parties who provide such services may be able to collect your Information and Personal Information (including your Log Data), and may set cookies on your computer or device to enable such features to function properly. Your use of any such third party services (whether social media services or otherwise), including any Personal Information you provide to such third parties and their collection and use of your Personal Information, are subject to the relevant third party’s own terms of services and privacy policies and not the SwanChat Terms of Service or this Privacy Policy, so please review those third party terms carefully. This Privacy Policy only applies to any Information collected by us, and does not apply to any services offered by or information practices of any third parties. We are not responsible for any third party use of any Information provided by you to them.

AGE RESTRICTIONS
Children under the age of 13 are not allowed to use SwanChat. We do not knowingly collect Personal Information from any children under the age of 13. Please contact our Privacy Officer if you believe we have any Personal Information from any children under the age of 13 – we will promptly investigate (and remove) such Personal Information. As set out in the SwanChat t Terms of Service – if you are between the ages of 13 and 18 (or the relevant age in your jurisdiction where you are considered a minor), your parent or guardian must agree to this Privacy Policy (both for themselves and on your behalf) before you can use SwanChat.

TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION

We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction. Any of the third parties referenced in the "Sharing of your Personal Information" section above may also be located and/or use and/or store your Personal Information outside of your jurisdiction for the purposes set out in that section. In both instances, your Personal Information may be transferred to jurisdictions that do not have data protection laws which are substantially similar to or serve the same purpose as the laws of your jurisdiction. We will ensure that all data transfers comply with applicable legal requirements (for example, by adopting suitable data protection policies and/or contractual measures). Should you wish to know more, please contact our Privacy Officer. We use a variety of generally accepted security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access or disclosure of Information – for example, we use encryption technology (such as SSL) to protect certain sensitive Information (such as Location Data) provided by you to us. Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. We do not warrant or guarantee the security of SwanChat or any information you provide to us through SwanChat. We may communicate with you electronically regarding security, privacy, and administrative issues relating to SwanChat. If we learn of a SwanChat security breach, we may attempt to notify you electronically by posting a notice within SwanChat or by sending direct communication to you. If you have any questions regarding the security of your Personal Information, please contact our Privacy Officer.

PERIOD OF USE OF YOUR PERSONAL INFORMATION
We will only retain your Personal Information for so long as is necessary to fulfil the purposes for which it was collected, as set out under the “How We Use Your Information” section above.

ACCESSING, UPDATING, AMENDING OR PORTING YOUR PERSONAL INFORMATION
Subject to applicable laws and regulations, you may have the right to: obtain confirmation that we hold Personal Information about you; access, rectify or delete your Personal Information that we maintain; request and receive a copy of the Personal Information you have provided us and to transmit this information to another provider. object to or request the restriction of processing of your Personal Information; and have the information deactivated, blocked, anonymised or deleted, as appropriate. To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us, including consent for email and targeted marketing communication and data transfers. We will use reasonable efforts to apply your preferences going forward. If you would like to update or amend your Personal Information within SwanChat, you may do so in the first instance by logging into your account and making the appropriate changes. For example, you may be able to delete certain Location Data that you have provided us via your device settings or the “Clear Location” option within SwanChat. If you wish to: make further changes to your Personal Information; exercise any of your rights mentioned above in this section; or to request the removal of an unauthorised SwanChat account, please contact our Privacy Officer. We will use reasonable efforts to respond to all such requests made to our Privacy Officer without undue delay and in accordance with any time limits required by law. Please note that your right to access Personal Information in the above manner may be limited in some circumstances by local law requirements. In some cases, we may not be able to update, amend or remove your Personal Information, in which case we will let you know why we are unable to do so – for example, certain requests may be extremely impractical or require disproportionate technical effort (e.g. any requests that relate to our backup systems), or are prohibited by law. Should your account be terminated by you or us for any reason, we will (subject to the above paragraph) take steps to ensure that your Personal Information is no longer available through SwanChat, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination. However, it is important to note that communications made by you using SwanChat may put your Personal Information in the hands of third parties that we cannot control. We will use reasonable efforts to respond promptly to requests, questions or concerns you may have regarding our use of Personal Information about you. Except where required by law, we cannot ensure a response to questions or comments regarding topics unrelated to this Privacy Policy or our privacy practices. International Data Transfers We are a global business. We may transfer Personal Information to countries other than the country in which the data was originally collected. For example: we operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction; and any of the third parties referenced in the "Sharing of your Personal Information" section above may also be located and/or use and/or store your Personal Information outside of your jurisdiction for the purposes set out in that section. In both instances, Your Personal Information may be transferred to jurisdictions that do not have data protection laws which are substantially similar to or serve the same purpose as the laws of your jurisdiction. When we transfer your Personal Information to other countries, we will protect that Personal Information as described in this Privacy Policy. In particular, we may need to transfer your Personal Information to countries that are not considered to provide an adequate level of protection under EU data protection laws. However, we ensure that all data transfers comply with applicable legal requirements (for example, by adopting suitable data protection policies and/or contractual measures). Should you wish to know more, please contact our Privacy Officer. By agreeing to the Privacy Policy, you consent to the transfer of your Personal Information for the purposes described in the Privacy Policy. You have the right to withdraw your consent at any time, but please note that if you do not consent to the transfer of if you withdraw your consent to transfer, you may not be able to benefit from all or some of our Services.

TRACKING TECHNOLOGIES
We may, from time to time, use cookies, log files, web beacons, scripts, tags and other tracking technologies to collect, use and store Information about you or relating to you. This section describes how we use such tracking technologies.